Expense managementMoss and the GDPR: agreement, role and data location.
Moss is a expense management tool. Its role depends on the activity, it explains how to get its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Expense management
- Usual role
- Depends on the activity
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Moss do with personal data?
Manage company cards, expense reports, receipts and business travel. That is how Privacyboard describes a typical use of Moss, as a starting point you can edit.
The data usually involved: names, Payment details, Employee data, receipts, travel details
Is Moss a processor or a controller?
Moss is controller or acts for third-party payment providers for Moss Data such as KYC and payment compliance data.
Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.
Where does Moss store personal data?
Moss does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to Moss?
For the usual use of Moss, companies most often rely on legal obligation and legitimate interests (GDPR Article 6(1)). Receipts and expenses must be kept for accounting and tax purposes; managing company cards rests on a legitimate interest.
The interest you would state: “Controlling company spending and reimbursing employees for business expenses.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest
Does Moss have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Moss does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: Nufin GmbH Terms and Conditions v11.0 (1 Jan 2025), clause 15.3.3: a DPA (v3.0, 1 Jul 2024) is concluded automatically with the platform agreement, Nufin GmbH as processor. No hosting location or transfer tool stated.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Open the Moss reference pageHow to declare Moss
- 1
In your privacy policy
Name Moss as a recipient, say what it is used for (manage company cards, expense reports, receipts and business travel) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Moss with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Moss to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Moss
- Limit who can see individual expenses, and review access when someone leaves.
- Check that receipts are kept only as long as accounting law requires.
- Check the role of the card issuer, which often acts as an independent controller for payment checks.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is Moss GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Moss is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Moss have a DPA?
Moss does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://getmoss.com/public/terms-and-conditions/20250101_INT-en_Nufin_GmbH_Terms_and_Conditions_v11.0.pdf.
Is Moss a data processor?
It depends on the activity. Moss is controller or acts for third-party payment providers for Moss Data such as KYC and payment compliance data.
Which legal basis applies when I use Moss?
For the usual use of Moss, companies most often rely on legal obligation and legitimate interests (GDPR Article 6(1)). Receipts and expenses must be kept for accounting and tax purposes; managing company cards rests on a legitimate interest. The interest you would state: “Controlling company spending and reimbursing employees for business expenses.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Moss store data?
Moss does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention Moss in my privacy policy?
Yes, if Moss handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Moss to my vendor list?
In Privacyboard, pick Moss from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
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Privacyboard is not affiliated with Moss. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.